Comments regarding a letter from the NRC to Mr. Dan P. Stinnett (Field Supervisor, US Fish and Wildlife Services), RE: Request for list of Protected Species within the area under evaluation for the Monticello Nuclear Generating Plant License Renewal (TAC No. MC6441). (3 June 2005).Comments (in italics) detail the Risks of Making a Generic Environmental Impact Statement:

The EIS must address the environmental impact due to continued operation for an extended (sic) license term, where there is more radioactive material to be stored, higher burnup rate waste is dangerous for longer periods, more casks needed, etc. Assemblies will increase from 1630 to 4512, nearly tripled, by 2030. (MS-V-8)

Additionally, due to the fact that a long-term storage facility is unlikely to be built anytime soon, and that facility will not have room for additional waste from Monticello, this issue will be affecting generations of Minnesotans and metro residents. (MS-X-1)

So I’m inquiring about the severe accident mitigation alternatives. […] what was very unclear to me when te EIS explained these different categories of release potential, extreme, more than 50 percent of the inventory of cesium iodine being released. And then large, between 20 and 50 percent, which, of course, is really a huge range I think in terms of impact. Medium, small and negligible.

It explained that the severity depends upon the amount of the release in relation to the time in which the general emergency was declared and people were alerted and were able to be, mitigation measures were able to be taken.

What was completely unclear to me in the environmental review is whether or not the NRC has any specific standards for this. How that decision is made? Who makes the decision as to whether the general emergency is declared? When people are notified? Whether they’re—and I think this bears upon the question of the water supply as well.

The NRC has failed to adequately address risks to ground water contamination. According to the NRC’s own study the soils at the Monticello site are primarily Hubbards which are highly permeable and also have limited available water capacity. These soils readily transmit rainwater and surface water to groundwater supplies. In the event of radio-active material seeping out of containment units it is quite likely that groundwater sources and even aquifers could become contaminated. (MS-S-25).

And so if we have a severe accident at Monticello and we contaminate a stretch of the river, we need to have a specific methodology of notification of all these communities and those individuals that may fish in the upper reaches of the Mississippi.” [This includes a population with a range of communities that have English as a Second Language or very little English fluency, including at least four southeast Asian languages.]

I also work with the North American Water Office, and my primary interest is that the Monticello Nuclear Facility is upstream from water intake, drinking water intake, for the Minneapolis city. And it is the only source of drinking water. And so I would charge the NRC in their EIS analysis if there is an accident and there is a substantive discharge into that waterway, we have no alternative drinking water. […] Who is going to supply the water supply for 2 million people?

The EIS needs to account for sensitive subpopulations. NRC models still use a hypothetical 154-lb adult white male (modeled after a Manhattan Project worker) for dosimetric modeling and protection standard setting.

The problems surrounding environmental concerns reveal broad segments of the population have been ignored by the NRC.

The EIS needs to account for increased vulnerability for women and the elderly.

The EIS needs to account for infants and children’s increased vulnerability.

Current NRC standards and models do not consider newborn’s special vulnerability to radiation. Many radionuclides are excreted in breast milk, providing a special exposure pathway for infants. The brain continues to develop during the first 2 years of life. Numerous studies show that ionizing radiation can impair the developing human brain and affect cognitive processes. Further evidence is from children treated for leukemia or brain tumors, although confounding factors cloud the issue somewhat. A recent study from Sweden examined 3000 men who received irradiation for a skin problem as young children. It clearly demonstrated a significant dose-response relationship for all cognitive tests at doses equivalent to those from computer tomography of the skull. IQ loss is a lifelong health effect. Several longitudinal birth cohort studies have shown that optimal brain development in utero and in the first years of life are a determinant for how well cognitive abilities are preserved in old age. In other words brain development impaired through radiation exposure during infancy and early childhood predicts cognitive decline in old age. Therefore costs from this health effect accrue over a long time. The risk for children to contract radiation-induced cancer is high, even higher than for women. For instance, the same radiation in the first year of life for bouys produces 3-4 times the cancer risk as exposure between ages 20 and 50. Female infants have almost double the risk as male infants. A study in the August 2003 issue of the Archives of Environmental Health showed that children growing up in regions with nuclear power plants develop cancer twice as frequently as controls/the national average. Milk teeth from the 47 cancer-stricken children contained higher levels of Sr-90. Radiation induced child health effects that need to be considered in the EIS are not merely loss of life and cancer, like leukemia later in life, but also chronic health conditions, such as increased chance of birth defects, impaired fertility or IQ loss. The societal impacts and costs due to lost earning potential and mental retardation deserve NRC’s special consideration. Unfortunately NRC de fact ignores the risk of low dose radiation in its protection standards. (MS-Y-22).

The EIS needs to consider non-cancer health risks. Newly emerging evidence points to the fact that radiation can cause a spectrum of effects, such as reproductive and cognitive impairment.

The EIS needs to show how NRC intends to monitor for health effects in the general population.

The EIS needs to include a dose commitment that integrates radiation dose over time. NRC calculates radiation exposure for only the year of radiation release. (In contrast most European nations use a dose commitment that integrates dose over time, rather than only a one-time release.) This non-dynamic modeling is akin to determining the cost of a loan merely on the basis of the principal. (MS-Y-10).

The EIS needs to consider the effects and costs of long-term exposures, in particular by several radionuclides including tritium. While most radionuclides emitted from Monticello’s nuclear power reactor are relatively short-lived, there are some with long half-lives (like C-14), and some with infinitely long half-lives (Ur238, 4.5 billion years) that can deliver harmful exposures for months, years, thousands and millions of years. Despite its relatively short half-live (12 y) tritium is of high concern. It is a highly mobile radionuclide moving anywhere hydrogen does. While it is a relatively weak beta emitter, humans can inhale, ingest, and absort tritiated water and food, where it becomes an internal hazard, irradiating the tissue. Tritium can bioaccumulate through the aquatic foodchain. However NRC’s generic EIS at 4.6.1.1 (Radionuclide Deposition) argues on the one hand that Tritium is not known to build up, but admits on the other hand that buildup is not explicitly accounted for in the aquatic food pathway. NRC’s tritium release limits remain lax, despite animal, human cell, and DNA studies indicating its toxicity. Paragraph 4.6.1 on public exposure falls woefully short on what needs to be considered at Monticello, and seems more intent to deliver assurances than science-based information. (MS-Y-11).

The EIS needs to consider physiological or ecological interactions that would mitigate exposures. Radionuclides can unite with carbon in the human body, plants, or animals. Even though Tritium passes through the human body in 12 days, some becomes organically bound and can remain in a person for much longer (450 to 650 days). One study even found traces of tritium in the body 10 years after exposure. Similar processes happen in the natural environment: as released radioactive gases decay, some form particulate and join other persistent radioactive isotopes released as fallout. Long-lived isotopes perist, accumulate and “bio-magnify” in biota through the foodchain. (MS-Y-12).

The EIS needs to consider the so-called “routine radioactive releases” for Monticello specifically. During Monticello’s operation radioactivity is both continuously emitted and periodically batch-released to air and water. It is unclear in what quantities and how often. These data should be presented in concise table format for the past two decades of operation. Dilution with large volumes of station circulating water into reservoirs, rivers and lakes makes the releases “disappear.” This is not “natural background” radiation. (MS-Y-6).

The EIS needs to quantify air releases.

Watershed: The EIS needs to define the impact on water. The EIS needs to accommodate for fluxuating water levels, erosion, changing weather patterns, thermal issues and temperatures (increasing water temp means that the water is too hot to take the cooling water from the reactors and the reactors have to shut down). The EIS needs to show water flow rates and respective volumes in which continuous and batch releases have and are expected to occur, and model the effects of these releases, taking into consideration the latest scientific evidence—not the references from 10 years ago as in the generic EIS. This modeling should include mitigating factors related to global climate change (such as volatile changes in available water quantity, especially of the Mississippi River).

[Response from NRC: “The specific impacts of climate change within a particular region or watershed are highly speculative and therefore beyond the scope of a NEPA review for reactor license renewal. Furthermore, any changes in the watershed characteristics would likely be gradual, allowing water use conflicts to be resolved as needed. Operating license holders re required to submit Annual Effluent Monitoring Reports and are also required to submit even reports during abnormal conditions.”]

We need to know where these reported releases are going, because unless we know where they go, we don’t know where the receptors are. And unless we don’t know where the receptors are, we don’t know what the biological consequences of that reception are.

We also need to consider the impact of growth in Metropolitan and surrounding area.